1. The Theory and Practice of Policies & Procedures David Bailey, Vice President – KHEAA Will Shaffner, Director – MOHELA Colleen Slattery, Federal Compliance Officer – MOHELA

2. Policy vs. Procedure Policies – Designed to Drive Rational Outcomes – Ensure Consistent Performance and Outcomes – Created to Convey Intent – Instilled to Document Commitment – Driven by Boards or Government Organizations Navigating the Sea of Change 2012 NCHER Knowledge Symposium 2

3. Policy vs. Procedure Examples of Policies – Security Policy – Philanthropy Policy – Customer Satisfaction Policy – Increasing the Number of College Graduates – Protecting Consumers Navigating the Sea of Change 2012 NCHER Knowledge Symposium 3

4. Policy Design Centralized Control Standard Approval Protocol Version Control Common Components Navigating the Sea of Change 2012 NCHER Knowledge Symposium 4

5. Policy vs. Procedure Procedures – Who – What – When – Where – Why – How (Department level) Should support Policy Navigating the Sea of Change 2012 NCHER Knowledge Symposium 5

6. Policy vs. Procedure Examples of Procedures – Security - New Hire Badging – Philanthropy - Charitable Giving – Customer Satisfaction - Ensuring Satisfied Customers - Escalation – Increasing Graduates - Greater Pell Accessibility or Broaden Admissions – Protecting Consumers - Complying with SCRA or Greater Transparency Navigating the Sea of Change 2012 NCHER Knowledge Symposium 6

7. Policy Drivers Internal and External Legislative/Statutory Regulatory (CFPB, FFELP, FSA – DL, other) PolicyProcedure Governance/Boards Mission and Strategic Plan PolicyProcedure

8. Policy Drivers Internal Business Need – Requirements that an Organization Must Follow – Achieve Goals and Objectives from Strategic Plan – Meet Internal Metrics Best practices – A Method or Technique that Consistently Shows Results Superior to those Achieved by Other Means – Efficiently Process and Service Loans – Transparency or Open Records Navigating the Sea of Change 2012 NCHER Knowledge Symposium 8

9. Policy Drivers CFPB – Increased Oversight Private Loan Origination Loan Servicing Ombudsman/Complaint Management – Servicemembers Civil Relief Act (SCRA), etc. – Increased Risk The CFPB can obtain “any appropriate legal or equitable relief with respect to a violation of Federal consumer financial law,” Navigating the Sea of Change 2012 NCHER Knowledge Symposium 9

10. Policy Drivers FFELP – Federal Register/NPRM – IFAP – Professional Associations, NCHER, etc. Federal Assets (DL, PUT, etc.) – CR / Change Request – Directives Other – Sandy, etc. Navigating the Sea of Change 2012 NCHER Knowledge Symposium 10

11. Policy Design Common Components – Purpose – Scope – Roles and Responsibilities – Management Commitment – Coordination among Organizational Entities – Compliance – Exceptions – General Information – Signatories – Terms and Definitions – Effective / Implementation Date Navigating the Sea of Change 2012 NCHER Knowledge Symposium 11

12. Procedure Design Common Components – Standardized Format Purpose Objective Scope Terms, Definitions, Acronyms – Desktop Procedures (step by step) – Review and Approval Process – Version Control – End User Acknowledgement – Annual Validation Navigating the Sea of Change 2012 NCHER Knowledge Symposium 12

13. Implementation Navigating the Sea of Change 2012 NCHER Knowledge Symposium 13

14. Navigating the Sea of Change 2012 NCHER Knowledge Symposium 14 Questions ????